34/3676 MM- General AM-General IPCLI Our Ref DS/SJS/1530 Date 10th February 2020 PLANNING PCL Planning Ltd 13a-1Sa Old Park Avenue Exeter Devon Forward Planning EX1 3WD Mid Devon District Council United Kingdom t: + 44 (0)1392 363812 Phoenix House www.pclplanning.co .uk Tiverton EX16 6PP plan n i ngconsu ltations@m iddevon. gov. u k Dear Sirs, MID DEVON LOCAL PLAN REVIEW - MAIN MODIFICATIONS CONSULTATION We have carefully considered both t he main and additional modifications proposed by t he Council. Housing Delivery It is apparent that t hose modifications fail to satisfactorily deal with t he matters of the inherent problem of a plan strategy that is dependent upon t he t imely delivery of new infrastructure. Since t his infrastructure is a pre-requisite to the t imely release of land for development and a clear pathway to achieving completions it was quite correct for t his matter to be raised by the Inspector (as he did in his note of 21/05/19): "I require the Council to provide, for my analysis, a projected housing directory for Years 1-5 and 5-10 incorporating realistic assumptions about the delivery of the TCRR, .... " (our underlining). However, as we pointed out in our response (dated 26/07/2019) to the Council's Housing La nd Supply Update (ED20) the Council have not set out, in any depth, a set of realist ic assumptions. Instead t hey have effectively eschewed t hose concerns. The Council rely upon t he due diligence undertaken by Homes England through the HI F assessment process (see appendix D to ED20). In our experience t hat exercise relies heavily on t he assumptions provided to HE by the Council. We have not seen t he DCC work programme referred to (at section 6 of ED22) therefore, so far as we are aware, t here is no substantive timescale before the examination to deal with t he identified matters of: • Land assembly (in particular) • Pla nning application (preparation/submission and determination) • Construction period (particularly bearing in mind the ground conditions) PCL Planning Ltd, Registered Office: 1A Parliament Square, Parliament St reet , Crediton, Devon, EX17 2AW Registered in England and Wa les No. 8300933 VAT No. 923955793 t hat enables scrutiny of t he realism of the assumptions that have been passed to HE. Our concern is t hat the Council rely upon a 'rose t inted' view of likely completions from Cullompton in t heir projected housing land supply. Therefore, in our opinion, t he plan has not been realistically prepared and will t herefore not be effective. G&T sites The second issue that serves to inhibit t imely completions is that of the Council's policy in relation to G&T pitch provision. The I nspector clearly understood t he implications of t he Council's policy approach (in the light of t he policy and practice of lending inst itut ions) and clearly advised t he Council to 'decouple' t heir approach to the provision of housing sites and G&T sites. Again t he Council have eschewed this advice and the modifications proposed fall well short of what is necessary to achieve this 'decoupling'. Conclusion It is unfortunate t hat t he Council have, rat her stubbornly, decided to continue with t heir preferred policies, as opposed to amend t hem in a substantive manner to satisfactorily deal with the two problems identified above. Bot h of these issues drive to the heart of soundness tests (hence why the I nspector pointed out that main modifications were necessary to deal with t hem). I n our opinion it is clear t hat since the Council have declined the opportunity to propose suitable modifications it should be concluded that the proposed plan will not be effective, having regard to t he tests of soundness at paragraph 35 of t he Framework (since it is not deliverable over t he plan period. Kind regards, David Seaton, BA (Hons) MRTPI For PCL Planning Ltd e: PCL Planning Ltd, Registered Office: 1A Parliament Square, Parliament Street, Crediton, Devon, EX17 2AW Registered in England and Wales No. 8300933 VAT No. 923955793 .